Europe.Hughes.com

Introduction

Hughes Network Systems Europe (“HNSE”) is strongly committed to protecting personal data.

HNSE is made up of different legal entities.  This statement is issued on behalf of the HNSE Group so when we use Hughes Europe, “we”, “us” or “our” in this statement we are referring to the relevant company in the Hughes Europe Group responsible for processing your data.  Hughes Network Systems Limited is the controller and responsible for this website.

This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others.  We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person.  Hughes Europe processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.  

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.  To find out more about our specific processing activities, please go to the relevant sections of this statement.

Our processing activities

To find out more please go to the sections of this statement that are relevant to you.

Business Contacts

Corporate Customers

Individuals whose personal data we may obtain incidental to providing our services to a business

Others who get in touch with us

Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)

Visitors to our offices

Visitors to our website

Data Security

We take the security of all the data we hold very seriously.  We have put in place appropriate technical and organisational measures to prevent your personal data form being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition we limit access to your personal data to those employees, agents, contactors and other third parties who have a business need to know. They will only access your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global group of companies and in common with other global enterprises providers, we use third parties located in other countries to help us run our business.  As a result, personal data may be transferred outside the countries where we and our customers are located.  This includes to countries outside the European Union ("EU") and to countries that do not have laws that provide specific protection for personal data.   We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.  The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

  • Other companies in our group
    For details of our group company locations, please click here (https://europe.hughes.com/find-us). We may share personal data with other group companies where necessary for administrative purposes and to provide services to our customers (e.g. when providing technical services involving knowledge and expertise from our staff in a different territory).  Our business contacts are visible only to, and used by, our group company users in Europe to learn more about a contact, client or opportunity they have an interest in (please see the Business contacts section of this privacy statement for more information about our processing of this type of data).

  • Third party organisations that provide business applications/systems, data processing or IT services to us
    We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

  • Third party organisations that otherwise assist us in providing goods, services or information

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, we buy telecoms circuits from telecoms providers in different countries, and telecoms equipment from manufacturers.  We use third party service organisations with the skills and local presence to provide field services on our behalf.  It may be necessary for us as part of our contract to our customers to share personal data with these suppliers, such as a contact name to arrange an appointment on site.

  • Auditors and other professional advisers

  • Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
    Sometimes we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 18 May 2018.

Data controller and contact information

The data controller is Hughes Network Systems Limited (the company registered in England under registration no. 05322680  and with its registered address at Hughes House, Rockingham Drive, Linford Wood, Milton Keynes MK14 6PD) and such other Hughes Europe company that is a contracting party for the purposes of providing or receiving services.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Legal Counsel
Hughes Network Systems Limited
Hughes House

Rockingham Drive

Linford Wood

Milton Keynes

MK14 6PD

Email: gdpr@hugheseurope.com
Phone: 01908 425300

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data

You have a right of access to personal data held by us as a data controller.  This right may be exercised by emailing us at gdpr@hugheseurope.com.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limit.

Amendment of personal data

To update personal data submitted to us, you may email us at gdpr@hugheseurope.com or, where appropriate, contact us via the relevant website registration page.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis such as legitimate interests or where it is necessary to perform a contract).  To withdraw consent to our processing of your personal data please email us at insights@hugheseurope.com or, to stop receiving an email from a Hughes marketing list, please click on the unsubscribe link in the relevant email received from us.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.  Some of these rights will only be available from 25 May 2018.  

If you wish to exercise any of these rights, please send an email to gdpr@hugheseurope.com.  

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to gdpr@hugheseurope.com.  We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the UK data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website.

Business Contacts

Collection​ ​of​ ​personal​ data

Hughes Europe processes personal data about contacts of businesses (existing and potential customers) using a customer relationship management system (the “CRM”).

The collection of personal data about business contacts and the addition of that personal data to the CRM is initiated by a Hughes user and will include name, employer name, contact title, phone, email and other business contact details.   In addition, the CRM may collect data from Hughes email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between Hughes users and contacts or third parties

Use​ ​of​ ​personal​ data

Personal data relating to business contacts will be visible to and used by Hughes users to learn more about an account, customer or opportunity they have an interest in, and may be used for the following purposes:

  • Administering, managing and developing our businesses and services

  • Providing information about us and our range of services

  • Making contact information available to Hughes users

  • Identifying customers/contacts with similar needs

  • Describing the nature of a contact’s relationship with Hughes

  • Performing analytics, including producing metrics for Hughes’ management, such as on trends, relationship maps, sales intelligence and progress against business goals.

In addition, Hughes uses an algorithm to evaluate the strength of interactions between Hughes and a business contact.  This ranking is primarily based on interaction frequency, duration, time since last interaction and response time.

Hughes does not sell or otherwise release personal data contained in the CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.

Data retention

Personal data will be retained on the CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact). We may also retain your data to ensure that you are no longer contacted if you wish to opt-out, or to record that your email address is no longer in operation. 

Corporate Customers

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask representatives of our corporate customers to only share personal data where it is strictly needed for those purposes.

Where we need to process personal data to perform a service for a corporate customer, such as to contact them, we ask our customers to provide the necessary information to the data subjects regarding its use.  Our corporate customers may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.

Generally, we collect personal data directly from our corporate customers.  

Use of personal data

We use personal data for the following purposes:

  • Providing services
    We provide a range of services (go to https://europe.hughes.com for information on our range of services).  All of our services require us to process a limited set of personal data in order to perform the service and to provide deliverables.  For example, we will require the name and contact details of someone to send our invoices to, for arranging a site visit to install equipment, or to call back concerning resolution of a system fault.

  • Administering, managing and developing our businesses and services
    We process personal data in order to run our business, including:
    - managing our relationship with customers;
    - developing our businesses and services (such as identifying customer needs and improvements in service delivery);
    - maintaining and using IT systems;
    - hosting or facilitating the hosting of events; and
    - administering and managing our website and systems and applications.

  • Security, quality and risk management activities
    We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to customers for quality purposes, which may involve processing personal data stored on the relevant customer file.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to customer engagements.  We collect and hold personal data as part of our customer engagement and acceptance procedures.  As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular customer (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).  

  • Providing our customers with information about us and our range of services
    Unless we are asked not to, we use customer business contact details to provide information that we think will be of interest to them about our business and our services, such as, industry updates and technology insights, other services that may be relevant and invites to events.  Where we do this we principally rely on legitimate interest as the basis for processing after carrying out a balancing exercise to ensure that our processing is not unreasonably intrusive.

  • Complying with any requirement of law, regulation or a professional body of which we are a member
    As with any provider of communications services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are always looking for ways to help our customers and improve the relevancy and impact of our business and services.  Where agreed with our customers, we may use information that we receive in the course of providing services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our customers, to improve our business, service delivery and offerings and to develop new Hughes technologies and offerings.  To the extent that the information we receive in the course of providing services contains personal data, we will take reasonable steps using commercially available methods to anonymise the data prior to using the information for these purposes. 

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years.

Individuals whose personal data we may obtain incidental to providing our services to a business

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our customers only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our customers to provide the necessary information to the data subjects concerned regarding its use, such as to explain that we are a supplier.  

We collect and use contact details for our customers in order to manage and maintain our relationship with those individuals.  Please see the Business Contacts section of this privacy statement for more information about our processing of this type of data.

Generally, we do not collect personal data of any of our customers’ customers unless it is necessary and for agreed purposes, such as contacting them to make an appointment to visit a site not under the control of our customer.

Where we may obtain personal data incidentally and not for agreed purposes is when fault finding on a network that we are managing for a customer or when co-operating with an organisation that has legal authority to receive our co-operation for their purposes.  

Use of personal data

We use personal data for the following purposes:

  • Providing communications services
    We provide a range of services, including communications services.  Some of our services require us to fault-find and resolve a technical situation for a customer, during which we may incidentally be exposed to personal data.  In this case we expect our customers to provide the necessary information to the data subjects concerned regarding its use.

  • Administering, managing and developing our businesses and services

  • Security, quality and risk management activities   

  • Complying with any requirement of law, regulation or a professional body of which we are a member
    As with any provider of communications services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.  We may also need to intercept communications traffic in order to comply with an order from a lawfully authorised organisation. 

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

For incidentally gathered personal data, we have no baseline retention period and act to remove it as soon as we become aware.

Others who get in touch with us

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication).  In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors

Collection​ ​of​ ​personal​ data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage our relationship with them, to receive services from them and, where relevant, to provide services to our clients.

Use​ ​of​ ​personal​ data

We use personal data for the following purposes:

  • Receiving services

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with secure off-site data storage services, we will process personal data about those individuals that are providing services to us.

  • Providing services to our corporate customers

Where a supplier is helping us to deliver services to our customers, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our customers (for example, where our supplier is providing engineers to go to a customer site to install equipment).

  • Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

- managing our relationship with suppliers;
- developing our businesses and services (such as identifying customer needs and improvements in service delivery);
- maintaining and using IT systems;
- hosting or facilitating the hosting of events; and
- administering and managing our website and systems and applications.

  • Security, quality and risk management activities

We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our procurement procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.

  • Providing information about us and our range of services

Unless we are asked not to, we use business contact details to supply information that we think will be of interest about us and our needs.

  • Complying with any requirement of law, regulation or a professional body of which we  are a member

As with any provider of communications services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Visitors to our offices

We have security measures in place at our various offices in the UK and Europe, including CCTV and building access controls.

There are signs in our offices showing that CCTV is in operation. The images captured are securely stored and only accessed by an authorised person on a need to know basis to look into an incident concerning damage or interference to property or injury to person.  CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We require visitors to our offices to sign in at reception and we keep a record of visitors for a short period of time.  Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

Visitors to our website

Collection of personal data

Visitors to our website (https://europe.hughes.com) are in control of the personal data shared with us except where, in common with other website operators, cookies are active.  We may capture limited personal data automatically via the use of these cookies.  Please see the section on cookies below for more information.  We also generate site usage statistics which is not personally identifiable information. Please see the section on site statistics below for more information.

We collect personal data, such as name, job title, company address, email address, and telephone number, from website visitors; for example when an individual subscribes to updates from us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.    

Important: Please do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Cookies

In addition to the information gathered as described above, there is a technology called "cookies" which can be used to provide you with tailored information from a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. We make use of cookies on the website so that we can better serve you when you return to the website. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. However, please note that disabling cookies may prevent you from taking advantage of certain features on the website.

Site Statistics

In addition to the information you knowingly provide, we keep track of the domains and IP addresses from which people visit us. We also collect site usage statistics such as Web browser types and page requests. This data is not personally identifiable and is used to more efficiently operate our business, prepare for network load demands, promote our services and administer the website. We may share with our affiliates aggregated statistical information about the use of the website.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to:

  • register for certain areas of the site;

  • subscribe to updates;  

  • enquire for further information;

  • distribute requested reference materials;

  • submit curriculum vitae;

  • monitor and enforce compliance with our terms and conditions for use of our website;

  • administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, paid-for content or other services limited to registered users; and

  • aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about our business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to insights@hugheseurope.com.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.  If there is an instance where such information may be shared with a party that is not a group company, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).  

On